Interpretation ID: aiam0067
Chief Engineer
FWD Corporation
Clintonville
WS 54929;
Dear Mr. Dando: Thank you for your letter of January 11, 1968, to Dr. William Haddon Jr., concerning the location of headlamps on vehicles which are used for snow plow service. I regret that a clerical error resulted in this late reply to your inquiry.; Snow plows are motor vehicles and subject to regulatory actions a established by the National Traffic and Motor Vehicle Safety Act of 1966.; Motor Vehicle Safety Standard No. 108 requires that vehicles to whic the standard is applicable be equipped with headlamps that are located not less than 24 inches nor more than 54 inches above the road surface (see Table II of the standard). This requirement does not prohibit the use of additional headlamps located at greater heights as illustrated by the photographs enclosed with your referenced letter.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service;